VARA Cybersecurity Compliance
VARA
2025
SECURE
ITSEC
SEC_PROTOCOL
ACTIVE
VARA Technology & Information Rulebook Compliance

VARA Cybersecurity
Compliance & Testing
Services

Meet every requirement of the VARA Technology & Information Rulebook 2025 with ITSEC — The cybersecurity partner trusted by regulators and innovators.

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What is VARA Compliance?

Technology & Information Rulebook — Effective 19 May 2025

Under VARA's Technology & Information Rulebook (effective 19 May 2025), all Virtual Asset Service Providers operating in Dubai must implement comprehensive cybersecurity controls to maintain their license.

These are not optional guidelines—they're mandatory licensing requirements that VARA actively inspects. Non-compliance can result in license suspension or revocation. Whether you're already operating in Dubai or planning to establish your VASP in the UAE, VARA compliance is mandatory for licensing

Independent Testing

Annual Red Team Simulations (Threat-Led Penetration Testing – TLPT) conducted by certified independent firms

Cryptographic Key Governance

Secure key lifecycle management, custody controls, and Hardware Security Module (HSM) integration

72-Hour Incident Response

Mandatory incident notification to VARA within 72 hours, including BCDR plans and response procedures

ITSEC ensures your platform meets every requirement

Our compliance framework is specifically engineered for VARA inspections, with audit-ready documentation and continuous monitoring to maintain adherence.

Industry Certifications & Accreditations

ISO 27001 Certified

Information Security Management

CREST Approved

Penetration Testing Excellence

OSCP Certified Team

Offensive Security Professionals

UAE Licensed

Dubai Economic Zone Authority

Trusted by VARA-Licensed Entities

EX

Leading UAE Exchange

BR

MENA Broker Platform

TI

Token Issuance Provider

SN

Settlement Network

DC

Digital Asset Custodian

CT

Crypto Trading Desk

Client names confidential per NDA agreements

Proven Track Record in VARA Compliance

500+

Assessments Completed

100%

VARA Compliance Rate

50+

Licensed Entities Served

24/7

Expert Support

VARA Technology & Information Rulebook: 6 Core Cybersecurity Requirements

The Technology & Information Rulebook establishes comprehensive cybersecurity mandates for all Virtual Asset Service Providers in Dubai. Non-compliance puts your license at risk.

VARA refers to Red Team Simulation as Threat-Led Penetration Testing (TLPT) under Rulebook §E

Red Team Simulation (TLPT)
Annual independent Threat-Led Penetration Testing under Rule E
ITSEC Solution: Simulated adversarial attacks
Continuous Monitoring
Ongoing vulnerability scanning & quarterly security audits
ITSEC Solution: Automated threat detection
Key Lifecycle Governance
Cryptographic key management & custody controls (Rule D)
ITSEC Solution: HSM integration & secure storage
CISO Appointment
Designated Chief Information Security Officer (Rule I)
ITSEC Solution: Executive security oversight
Incident Response
72-hour incident notification to VARA (Rule H)
ITSEC Solution: BCDR & response planning
Access Controls & Authentication
Multi-factor authentication & role-based access management
ITSEC Solution: IAM policies & audit trails

VARA Technology & Information Rulebook: 6 Core Cybersecurity Requirements

With 20+ years of cybersecurity leadership, ITSEC is the only firm engineered to pass VARA inspections. Our specialized compliance framework addresses every requirement of the Technology & Information Rulebook ahead of the May 2025 deadline.

UAE-based Red Team experts (TLPT certified)
Regulator-grade testing and reporting
Virtual CISO & PDPL Data Protection
Proven audit success track record
Continuous vulnerability monitoring
View VARA Compliance Map (PDF)
Shield
Compliance-Ready Security Architecture
Rulebook-Aligned Testing
Evidence-Based Documentation
Continuous Compliance

ITSEC Services Mapped to VARA Requirements

VARA Compliance Table
VARA Mandate ITSEC Solution Compliance Outcome
E.1 – Annual Independent Testing Red Team Simulation (Threat-Led Penetration Testing – TLPT) & VAPT Satisfies external testing requirement
D – Key Lifecycle & Storage Cryptographic Key Governance & HSM Integration Prevents single point of failure
H – 72-Hour Incident Reporting Incident Response Plan & BCDR Design Achieves regulatory resilience
I – Appointed CISO Virtual CISO & Oversight Meets governance expectations
F – Continuous Monitoring & Scanning Quarterly Security Audits & Vulnerability Scanning Ensures ongoing compliance posture

Your Compliance Journey

Track your progress towards VARA compliance

Initial Assessment
Complete 100%
Red Team Testing
In Progress 85%
Documentation
Review Phase 90%
VARA Ready
Final Validation 95%

Tailored Solutions for Every VARA Entity

Red Team / TLPT Testing

Simulated attacks on trading, hot wallets, & API endpoints.

Wallet Security Assessment

Hot/cold wallet architecture review and custody control validation.

SOC Integration

24/7 security operations center setup and threat monitoring.

SIEM Implementation

Security Information & Event Management w/ real-time alerting.

Audit Logging

Comprehensive transaction  access logging for regulatory reporting.

Threat Monitoring

24/7 security operations center setup and threat monitoring.

Vault Security Assessment

Hardware security module (HSM) integration and cold storage validation.

Key Management Protocols

Multi-party computation and threshold signature scheme reviews.

Asset Transfer Controls

24/7 security operations center setup and threat monitoring.

Smart Contract Security

DeFi protocol audit and liquidity pool vulnerability assessment.

Oracle Security Review

Price feed validation and manipulation resistance testing.

Collateral Management

24/7 security operations center setup and threat monitoring.

Portfolio Platform Security

Investment management system penetration testing and API security.

Fund Administration Controls

NAV calculation integrity and reporting system security audits.

Client Asset Segregation

Multi-tenant architecture security and data isolation validation.

Smart Contract Audit

Line-by-line code review of token contracts and deployment security.

Key Custody Reviews

Multi-signature governance and key management protocol validation.

Issuance Platform Security

End-to-end security assessment of token issuance infrastructure.

5-Step VARA Compliance Process

Day 1
Initial Consultation
Deliverables:
Scope definition ●
gap analysis ●
Project timeline ●
Day 2 - 3
Documentation Review
Deliverables:
● Gap analysis report
● Priority recommendations
● Remediation roadmap
Week 1-2
Red Team Simulation (TLPT)
Key Deliverables:
TLPT execution ●
Vulnerability assessment ●
Attack simulation report ●
Week 3
Remediation & Documentation
Key Deliverables:
● Security fixes
● VARA-compliant policies
● Regulator-ready reports
Quarterly
Ongoing Compliance
Key Deliverables:
Vulnerability scans ●
Compliance updates ●
Annual TLPT refresh ●

Security and Compliance Service Tiers

Tailored service tiers for VARA compliance—pick the coverage you need, from foundational controls to audit-ready programs.

Essential Compliance

Perfect for VASPs preparing for theirfirst VARA inspection

Contact Us

Custom pricing per entity

✔ Annual Red Team Simulation (TLPT
✔ Vulnerability Assessment & Penetration Testing
✔ Basic Key Governance Framework
✔ 72-Hour Incident Response Plan
✔ VARA-Compliant Documentation
✔ Quarterly Vulnerability Scans
✔ Email Support
Get Custom Quote
Complete Assurance

Comprehensive coverage for activeexchanges and broker-dealers

Contact Us

Custom pricing per entity

Everything in Essential, plus:
✔ Virtual CISO Services (50 hours/year)
✔ Advanced Key Lifecycle Management
✔ HSM Integration & Configuration
✔ SOC Setup & SIEM Integration
✔ Monthly Security Reviews
✔ 24/7 Incident Response Hotline
✔ Dedicated Compliance Manager
Get Custom Quote
Enterprise Shield

White-glove service for high volumeplatforms & multi-entity

Contact Us

Custom pricing per entity

Everything in Complete, plus:
✔ Full-Time Virtual CISO (Unlimited)
✔ Multi-Entity Compliance Coordination
✔ Smart Contract Security Audits
✔ Custom Security Architecture Design
✔ Weekly Status Meetings
✔ Priority VARA Inspection Prep
✔ Continuous Threat Monitoring
✔ SLA-Backed Response Times
Get Custom Quote

Trusted by VARA-Licensed Leaders

Join dozens of exchanges, broker-dealers, and issuers who achieved compliance with ITSEC

"The Virtual CISO service exceeded expectations. ITSEC understood VARA requirements better than firms charging 3x their rate."

M

Michael Chen
Chief Technology Officer
"Passed VARA inspection with zero findings. ITSEC's cryptographic key governance framework is exactly what regulators wanted to see."

M

Ahmed Hassan
Head of Security
"Professional, thorough, and regulator-grade documentation. ITSEC's incident response planning was comprehensive and practical."

M

Elena Rodriguez
VP Operations

VARA Compliance Case Study

The Technology & Information Rulebook establishes comprehensive cybersecurity mandates for all Virtual Asset Service Providers in Dubai. Non-compliance puts your license at risk.

100%
Compliance Achievement
The Challenge
High-volume Dubai-based crypto exchange facing first VARA inspection with incomplete security documentation and no prior penetration testing.
"ITSEC's Red Team Simulation revealed vulnerabilities we didn't know existed and helped us fix them before VARA's inspection. Their regulator-grade documentation was exactly what the inspectors needed. We passed with zero findings."

— CISO, Licensed VARA Exchange
Dubai, United Arab Emirates
Key Deliverables:
☑ Comprehensive TLPT (Red Team) Report
☑ 72-Hour Incident Response Plan
☑ Quarterly Vulnerability Scanning Setup
☑ Cryptographic Key Governance Framework
☑ Virtual CISO Oversight Program
☑ VARA Audit-Ready Documentation
The Solution
3-week TLPT engagement + key governance framework implementation + Virtual CISO oversight program.
3
Weeks to Compliance
0
Inspection Findings
Frequently Asked Questions

VARA Cybersecurity Requirements Explained

When does VARA's Technology & Information Rulebook take effect?
VARA's Technology & Information Rulebook becomes effective on 19 May 2025. All Virtual Asset Service Providers must be fully compliant by this date. This includes implementing Red Team Simulations (TLPT), cryptographic key governance, CISO appointment, incident response procedures, and continuous security monitoring. ITSEC recommends starting your compliance assessment at least 3-4 months before the deadline to ensure adequate time for remediation and documentation.
What is TLPT and how does it relate to Red Team Testing?
TLPT (Threat-Led Penetration Testing) is the formal VARA term for a Red Team Simulation — a controlled cyber-attack exercise that tests your real-world defenses under the Technology & Information Rulebook (effective 19 May 2025). It goes beyond standard penetration testing by simulating actual threat actor techniques to evaluate your organization's detection and response capabilities.
How is Red Team different from regular penetration testing?
Penetration testing identifies vulnerabilities in specific systems or applications. Red Team Simulations (TLPT) replicate sophisticated attacks to test your entire security ecosystem — including people, processes, and technology. Red Team engagements evaluate your security operations center, incident response procedures, and staff awareness in addition to technical controls. This comprehensive approach is what VARA requires under Rule E.
Do we need a CISO for VARA compliance?
Yes. Under VARA's Technology & Information Rulebook (Rule I), all Virtual Asset Service Providers must appoint a Chief Information Security Officer (CISO) or equivalent senior security executive. This individual must have sufficient authority and resources to oversee cybersecurity operations. ITSEC offers Virtual CISO services for organizations that need to fulfill this requirement without hiring a full-time executive.
How soon must incidents be reported to VARA?
Under Rule H of the Technology & Information Rulebook, VASPs must report material cybersecurity incidents to VARA within 72 hours of discovery. This includes any incident that materially affects operations, customer data, or assets. ITSEC's incident response planning ensures you have the procedures and documentation required to meet this strict timeline.
How often must security testing be performed?
VARA requires annual independent Red Team Simulation (TLPT) testing under Rule E, along with quarterly internal vulnerability scans and continuous security monitoring. ITSEC provides comprehensive testing schedules that satisfy all VARA requirements while minimizing operational disruption.
What are the consequences of non-compliance?
Non-compliance with VARA's cybersecurity requirements can result in license suspension, financial penalties, mandatory remediation under regulatory supervision, or license revocation. VARA conducts regular inspections and can impose enforcement actions for failure to meet Technology & Information Rulebook standards.
How long does a VARA compliance assessment take?
A comprehensive VARA cybersecurity assessment typically takes 2-4 weeks depending on the complexity of your platform and scope of services. This includes Red Team Simulation (TLPT), key governance review, incident response evaluation, and documentation preparation. ITSEC works with your team to minimize operational impact.
Can you help us prepare for a VARA inspection?
Yes. ITSEC specializes in VARA inspection preparation, including gap analysis, documentation review, remediation guidance, and mock inspections. Our compliance framework maps directly to VARA's assessment criteria, and our deliverables are designed to satisfy regulator requirements.
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